Minnesota v. Olson

Supreme Court of United States (1990)

Respondent/Defendant: Olson; the defendant was involved in robbery and murder. The police found out that he was staying with his friends. The police surrounded the house and then made a forced entry and arrested the defendant. The Supreme Court of Minnesota reversed the conviction by ruling that since there there were no exigent circumstances, the officers should have obtained a warrant before arresting the defendant. Now the state appeals and argues that they did not need a warrant because the defendant was staying in his friend's house and also the state asserts that there were exigent circumstances.

Issue: 1. Did the defendant have reasonable expectation of privacy in the apartment? (Katz Test) 2. Were there exigent circumstances?

Holding: 1. Yes 2. No

Key Facts: In order to have exigent circumstances, the police must show that they were arresting a fleeing felon, or there was probable cause to believe that evidence of the crime was going to be destroyed, or there was imminent danger to the police or others posed by the felon.

Legal Reasoning: The court ruled that since the defendant was an over night guest, he had reasonable expectation of privacy under Jones v. United States. The court further ruled that since the police had already surrounded the apartment, there were no exigent circumstances and the police should have waited for the defendant to come out of the house. The court ruled that under Payton v. New York, the police officers need a warrant when arresting someone in his house and since the police officers in the current case did not have such warrant, the ruling of the lower court was affirmed.

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